ML17187B005
| ML17187B005 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 05/27/1997 |
| From: | Kropp W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Jamila Perry COMMONWEALTH EDISON CO. |
| References | |
| CAL-RIII-96-16, NUDOCS 9706100261 | |
| Download: ML17187B005 (41) | |
Text
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Mr. J. S. Perry Site Vice President Dresden Station
- Commonwealth Edison Company 6500 North Dresden Road Morris, IL 60450 May 27, 1997
SUBJECT:
DRESDEN CONFIRMATORY ACTION LETTER MEETING
Dear Mr. Perry:
This refers to the meeting conducted at the Training Center and the Dresden Nuclear Power Station in Morris, Illinois on May 12, 1997. This meeting was to discuss the status of your actions related to the NRC Confirmatory Action Letter (CAL) No. Rlll-96-016.
In accordance with Section 2. 790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosures (the agenda and handouts provided by your staff at the meeting) will be placed in the NRC's Public Document Room.
We appreciate your cooperation in this matter. If you have any questions regarding this meeting, please contact me at 630/829-9633.
Docket No. 50-237 Docket No. 50-249
Enclosures:
- 1.
Attendance List Sincerely,
/s/ W. J. Kropp Wayne J. Kropp, Chief Reactor Projects Branch 1
- 2.
Licensee Presentation, Dresden Station Presentation to NRC on Status of CAL Action Items Document Name: R:\\L TRS2LIC\\CECO\\DRES\\MTGLTR512.DRP To receive a copy of this document, indicate in the box "C" = Copy without attach/encl "E" = Copy with attach/encl "N" = No copy OFFICE Riii
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NAME Lerch/co f.J.-µw' Kropp \\J.Y DATE 05/J..7/97 05/J.1197 OFFICIA.L RECORD COPY 9706100261 970527 I
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_____ __LJ_ __ j 11111111111111111111111111111111 llll llll 3
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'.1'(1 J. cc w/encl:
T. J. Maiman, Senior Vice President Nuclear Operations Division Distribution:
D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer T. Nauman, Station Manager Unit 1 M. Heffley, Station Manager Units 2 and 3 F. Spangenberg, Regulatory Assurance Manager I. Johnson, Acting Nuclear Regulatory Services Manager Richard Hubbard Nathan Schloss, Economist Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Document Control Desk-Licensing Docket File w /encl PUBLIC~ w/encl DRP w/encl Project Manager, NRR w/encl Project Manager Unit 1, NRR w/encl OC/LFDCB w/encl Riii PRR w/encl CAA 1 w /encl (E-Mail)
A. B. Beach, w/encl Riii Enf. Coordinator, vii/encl DRS (2) w/encl SRI LaSalle, Dresden, Quad Cities w /encl RAC 1 (E-Mail)
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ATTENDANCE LIST Commonwealth Edison <ComEd>
Dresden Station J. S. Perry, Site Vice President R. D. Freeman, Site Engineering Manager J. M. Heffley, Units 2 and 3 Station Manager D.
Winchester; Site Quality Verification Manager F. A. Spangenberg, Regulatory Assurance Manager J. R. Basak, Engineering Assistance Group Manager R.
Scott, Independent Safety Evaluation Group E.
Connell Ill, Design Engineering Superintendent Corporate Office H. W. Keiser, COMED Chief Nuclear Officer E. R. Netzel, Supplier Evaluation Services Director*
R.
Renuart, Configuration Management and Engineering Assuran.ce Nuclear Regulatory Commission <NRC>
A. B. Beach, Regional Administrator, Region Ill G. E. Grant, Director, Division of Reactor Safety (DRS), Riii R. A. Capra, Director, Project Directorate 111-1, NRA J. A. Grobe, Deputy Director, Division of Reactor Safety, Riii J: A. Gavula, Acting Chief, DRS, Engineering Specialists Branch 1, Riii G. M. Hausman, Reactor Inspector, DRS, Riii W. J. Kropp, Chief, DRP, Branch 1, Riii D. E. Roth, Resident Inspector, Dresden
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ENd.oSURE 2 ComEd DRESDEN STATION Dresden Station I
. Presentation To NRC on Status of CAL Action Items *
. May 12, J997
ComEd DRESDEN STATION Russell Freeman I
Joseph Basak Edward Connell Carl Richards Edward Netzel Robert Renuart Russell Freeman
- All AGENDA Introduction I Opening Remarks
- Dresden Engineering Assurance Group (DEAG) Recent Activity DEAG Effectiveness Corrective Action Record (CAR)
Effectiveness of DEAG Review of Safety Evaluation Design.Basis Initiative Program Results of Dresden Engineering Audit Engineering Audits Common Issues and Trends Scope and Findings of the Westinghouse and Duke Engineering Audits
-Expanded S&L Audit* -
ComEd Follow-up to the Duke Audit.
Closing Remarks Commitments And Current Schedule Op~n P.iscussion
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ComEd DRESDEN STATION Engineering R. D. Freeman Site Engineering Manager
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l ComEd DRESDEN STATION I
Dresden Engineering
- Assurance Group Joe Basak
ComEd DEA G Activities DRESDEN STATION
- .42 Engineering Pro
__ ducts Reviewed 17 Safety Evaluations. -
. 9 Comments 14 Operability Assessments 2 Comments 6 Calculations
- 3 Comments 1 Design Change Acceptable.
-1 Temporary Alteration AcQeptable 3 Other * *
- Comments on 15-3 PIF's initiated, others being trended
ComEd DRESDEN STATION 0.8 J!1 c eo.7.
E 0 o.6 IO
~
M'0.5
~
0 gu.4
~
0 C>0.3
~
~0.2
~...
f\\lbr-97 DEAGStatus Performance Indicators Arx-97
~-97 Month
~AD
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-ts-Q:J Btal
~50.59
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ComEd DEAG Status (continued)
DRESDEN STATION
- DEAG Effectivenes*s -** *
- SQV Unresolved Item (CAR 12-97-039)
- ** Increase.review of Calculations - Sample On
.SiteN endor - all disciplines
- e.
- Operability Evaluations - No Technical Issues in SQV Audit
I ComEd Sa/ ety Evaluations DRESDEN STATION D'esden Safety Evaluation Perfonnance Indicators 90%
80%
7f1'/o s>O°lo
~ 50%
... - _afslte 0
~
--e-fAG(3,4,5)
Cll a:: 40°/o
--fAG(4,5)
~
0 30%
".),._ - - - - - - - - - - -.. - -.. - - - - - -
2f1'/o - - - - - - - - - - -
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Afx-97
ComEd Safety Evaluations DRESDEN STATION Performance Indicators.
- DEAG Assessment
% of Category 3, 4 and 5
- Offsite Assessment
% ofUnacceptables in 6 categories
ComEd DRESDEN STATION Design Engineering CAL Actions E. C. Connell, III Design Engineering Superintendent
ComEd Design Basis Initiative DRESDENSTATION Remaining Dresden 1997 Commitments
- Design Basis and Calculation Validation for 6 Risk Signific_ant Systems *. *
- Validation ofDBDs For These Sy~tems
- Review of Existing DBDs Against UFSAR*
Requirements
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ComEd DRESDEN STATION Design Basis Initiative 6 Systems Selected For Design Basis &*
Calculation Validation
- Safety Related *125/250 VDC *
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- Low Pressure Core Injection System (LPCI)
- Containment Cooling Service Water (CCSW)
- Turbine Building Closed Cooling Water (TBCCW)
- Service *Water (SW)
Initiation Logic
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ComEd DRESDEN STATION Design Basis Initiative Design Basis & Calculation Validation for 6 Systems
- Capture. and Link* The Commitments In DBdb to SSC
- Validate Each Design Basis Commitment Through a Spec, Cale, Procedure. Or A Program
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- Update Associated DBD as Necessary e
- Revise/Create Required Cale, Procedure Or Program, If Required
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ComEd Design Basis Initiative DRESDENSTATION DBD Validation For The 6 Systems
- Validate The Fallowing Three System DBDs in 199*7.
- Safety Related 125/250 VDC.
- Low Pressure Core Injection {LPCI)
- Containment Cooling Service Water (CCSW)
- No Existing DBDs For The Following Three Systems
- Service* Water (SW).
- Turbine Building Closed Cooling Water (TBCCW)
- Emergency Core Cooling System (ECCS) Initiation Logic
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ComEd Design Basis Initiative DRESDEN STATION Revision & Creation of Calculations
- 40 Calculation Revisiori/Creation Has Been Identified During Key Parameter Review
- Revise/Create 23 Calculations *Pertaining T-o The 6 Systems Being Validated, With The Remaining 17 Calculations To Be Started in 1998"
- Calculations Will Be Reviewed and Accepted By Com*Ed.
ComEd Design Basis Initiative DRESDEN STATION
. Existing DBD Review Against UFSAR
, When November 8th Letter Was Issued, Corporate Design Basis Initiative Program Did Not Exist
- DBdb Has Been Developed And Is Being Installed To Capture AffThe Design Basis Information During UFSAR, TS, SER, DATR, Calculation and Procedure Review
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ComEd DRESDEN STATION Design Control..
SQV Audit 12-97-16 Integrated I Shared ReSource Audit
ComEd DRESDEN STATION Team Composition/Experience
- .. Eight (8) Person Audit Team*
- 4 Technical Specialists (Contractors)
- 4 ComEd Auditors, All Engineers
- > 100 Years of Combined Engineering
- Experience (Nuclear)
- > 70 Years Directly Related To Design Activities*
- Three (3) Team Members Were Licensed
- Professional Engineers
ComEd Audit Scope DRESDEN STATION
- Design Process Including:
- Design Inputs
~ Assumptions
- * - Configuration Management
-.Calculation Accuracy
- Interfaces
- *Procedure Adequacy and Adherence
- 10 CF*R.50.. 59's and UFSAR Changes
- Engineering Assurance Group Effectiveness.
- Operability Reviews I Determinations
- Corrective Action Effectiveness
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ComEd DRESDEN STATION Selection.Basis For The
. Calculations Reviewed
.
- Selection Based On The Following Concepts:
- - A Portion Would Represent New Modifications, Setpoint Changes, or Other Issues Related To The Pending D3Rl 4 Outage
- They Would Represent A Cross-Section of Old (Pre-1.S.I.) and New (Post-1.S.I. Corrective Action). _Calculations
- They Would Represent A Cross-Section of ComEd and Vendor Prepared Calculations
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ComEd Audit Preparation & Duration DRESDEN STATION
- Audit Prep Was a Sev.en Site Effort
- Involved Many Levels of.Management Including:.
- SQV Directors
- Audit Supervisors *
- Lead Auditors with.Engineering Disciplines
- Corporate Nuclear Oversight Input
- Dresden~ 3 Week Audit 3/10/97 to 3/27/97
ComEd Audit Preparation & Duration (Continued)
DRESDEN STATION
- Audit Results:
~ 5 Level II Findings - One (1) is Specific To Calculations
- 5 Level III Findings
- 2 Unresolve*d Items - Requires Further Review/Monitoring
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ComEd Calculations CAR DRESDEN STATION
- Level II Finding #12-97-036
- 20 calculations reviewed during the audit
- 12 found with some level of.error /weakness
- 8 of 12 were new calculations (12/1/96 or later)
- None of the 12 calculations in.question resulted in the final product being outside of acceptable tolerances.
e
. From a results viewpoint, t4e calculations were technically correct.
ComEd Summary of Calculations DRESDEN STATION
- 10 calculations prepared by ComEd
- 10 calculations prepared by A/Es
- Sargent and Lundy(2)
- Duke Engineering Services (4)
~ Vectra (3).
. - Pacific Nuclear (1)
- Calculation concerns were rated on a scale of 0 to 5 (with 5 being the most significant)
- 10 category 0 & 1 co~cems (Admin or editorial error)
- 1 category 2 concerrl (P9tential to erode the design margin) 1 category 3 concern (Design mar*gin eroded)
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ComEd Calculation DRE 96-0051 DRESDEN STATION
~. Prepared by ComEd
- SQV rated as a Category 3 concern _
- Topic: Fault current.and engineerii;igjudgment
Purpose:
Determine acceptable *fault current
- Issue: Calculated *10,214 amps. Breaker name plate rated for 10,000 *amps. Justification for the acceptability of the additional 214 amps was "engineering judgment" due to losses, impedences, etc.. Numerical values for the losses were not provided within the calculation.
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,I' 1-ComEd Calculation DRE 97-0040 DRESDEN STATION
~ Prepared by ComEd
- SQV rate.d as a Category 2 concern *_
- Topic: Seismic qualification for 480V switchgear
Purpose:
Determine if the flexibility of telescoping channels_ is accept~ble-
- Issue: Concern dealt with the determination of seismic "g" values. The flexibility of the channels was not calculated._ An EPRI letter dealing with the channels was not referenced_ in the calculation, and was not provided as justification for the calculation result.
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ComEd Summary DRESDEN STATION
.
- Calculation issues revolved around problems with the documentation of assumptions and administrative errors
- Process corrective actions as a result of previously identified issues have not been completely effectiv*e.
- No calculations were invalidated or
- determined to be technically incorrect.
ComEd DRESDEN STATION Supplier Evaluation Services E. R. Netzel
'.s:.
.supplier Evaluation Services Director I
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ComEd Westinghouse Audit (Columbia)
DRESDEN STATION Scope: 14 Calculations
- Engineering review package and calculations for axial repositioning of.wet annular burnable absorbers
- Secondary source design reports. for Braidwood and Zion
- Calculations associated with 17xl 7 grid design
- Engineering review and calculations associated with 3-tab inconel grid design Results:
No calculation issues Transposition error from test report to Engineering review package.
Verified final test report was correct One Engineering report-Editorial error (corrected immediately).
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I ComEd Duke Audit DRESDEN STATION
.
- Scope: 26 Calculations performed by Duke e
Engineering & Services (including. Vectra, Impell &
Pacific Nuclear)
- - Spanning three years
- Population included calcula~io.ns from five.sites
- 9 Mechanical * *
- 11 Structural
- 4 -Electrical
- 2-I&C
- 16 Vectra
- 5 Impell
.- 3 DE&S
-* 2 Pacific Nuclear
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ComEd Duke Audit (Continued)
DRESDEN STATION
- Results:
- Findings* *unresolved It~m (ComEd)
- Issues:
Calculations were found to have design control deficiencies Ineffective independent design review Internal audits were programmatic and not effective in identifying technical
. issues Duke has not incorporated the requirements of the ComEd NEP 's in their design procedures
ComEd DRESDEN STATION
, Bechtel Duke GE (NSSS) 1997 AB Audits
. Offsite
.Site(s)
Off site CIA Follow-up Off site Site(s) 1st Qtr 3rd Qtr 2nd Qtr 4th Qtr
. 3rd Qtr 4th Qtr
. Complete Complete.
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ComEd DRESDEN STATION
, Siemens (Fuel)
- (Fuel)
S&L 1997 AE Audits (Cont.)
.* Part 1
- Part 2 Off site Part l *.
Part 2 CIA Follow up
.1st Qtr
.3rd *Qtr.
3rd Qtr 2nd Qtr 3rd Qtr 2nd Qtr Complete Complete
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ComEd DRESDEN STATION Corporate Engineering Activities Bob Renuart Chief.Engineering, Configur_ation Management and Engineering Assurance
'. '11
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ComEd S&L Expanded Cale Review DRESDEN STATION
- Reviewed 50 Cales of a similar type as ComEd Audit
- 20 =No errors 10 = Category 1 -.Editorial 20 = Category 2 - Include minor COJ1?-putational errors, but no impact on calculation
- Problem Statement Minor Computational errors are precursors to bigger errors l
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ComEd S&L Expanded Cale Review DRESDEN STATION
.
- Two trends: Wrote two Trend PIFs
- 7 Missing formulae for intermediate steps
- 5 Errors related to Pressure Drop Cales
- Follow up Actions
- Revise checklists to pick up editorial, format errors
- Training on Pressure Drop Cales with heightened oversight
- Trend revi~w comments for effectiveness *and discovery of other problems
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DRESDEN STATION Duke Engineering
& Services Audit Results ComEd 14 Calculations determined discrepant (None were reviewed by ComEd EAG)
. (2) Category 3 (potential erosion of design margin)
(2) Category 4 (some erosion of design margin)
- Duke is tracking in their Correction Action Program. Six will get root cause evaluations, the remainder will be trended
- Immediate evaluation by Duke was that there were no operability issues -
stations also notified in order to allow them to conduct operability assessments
- Duke letters sent to ComEd Site Engineering Managers
- Most significant problems Incorrect/Incomplete design input on a setpoint calc - (Category 4)
Using wrong equations in same calculation (one conservative, one nonconservative) somewhat offsetting - (1 Category 4; 1 Category 3).
One instance of use of unverified reference as design input - (Category 3)
Instance of failure to use NDIT for input - (Category 2)
Procedural/format nonconformances '-(Category 2)
One instance of issuing advanced information prior to completion of substantiating calculation - (Category 2)
Lack of clear statements of referen.ces and assumptions - (Category 2)
DRESDEN STATION
- Duke Engineering
& Services Audit Results ComEd
- Root cause determination on Duke PIRs may drive further actions - expected complete by May 31.
- Duke immediately performed an overview of a sample of similar calculations
- Duke setting up a more robust overview_process Formed Quality Executive Steering Team Implemented Engineering Assurance technical reviews and mentoring Calculation training on lessons learned and* good practices scheduled to be complete by end of2Q97 Major revision to DE&S QA program.planned to resolve programmatic finding from this l.
audit
- ComEd EA Group Over-viewing future Calculations generated by DE&S